Interlocal Collaboration: Metropolitan Area Planning Council Initiatives

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Stephen McGoldrick
Deputy Director, Metropolitan Area Planning Council

The Problem

Massachusetts, like most other states, is experiencing severe fiscal stress that is forcing deep spending reductions on both the state and local levels. Local governments in Massachusetts are already feeling the pain of local aid cuts and sending out layoff notices to police, fire, and public health employees and drastically reducing or eliminating programs. Most would agree that Massachusetts’s fiscal health will not improve in the immediate future, making more local aid cuts inevitable and forcing municipal managers to think creatively about how to maintain core services. The problem becomes even more vexing as federal unfunded mandates, coupled with federal budget tightening, trickle down to already strapped states. To help absorb the blow, the states push more responsibilities down to the local level while restricting the localities’ ability to raise additional revenue.

The last time Massachusetts faced a similar situation, in the late 1980s and early 1990s, several local governments were placed under the scrutiny of state-appointed finance control boards and received massive infusions of state assistance to keep them afloat; the city of Chelsea fell into receivership. Bail-outs and state boards that oversee municipal finances, with the exception of the Chelsea Receivership, have not provided long-term solutions to the problems rooted in Massachusetts governmental structure. Yet the “perfect storm” that prompted the Commonwealth to take such drastic action on localities back then is brewing once again. In April of this year, the Massachusetts Department of Revenue issued a report that recommended a “finance advisory board” for the city of Springfield.1

One of the greatest impediments to municipal fiscal health in Massachusetts is the inherent inefficiency of replicating every municipal service and carrying the cost of service delivery overhead and infrastructure in each of its 351 municipal budgets. Some municipalities cannot provide certain services due to a lack of fiscal capacity. Some states empower county government to offer a range of services that benefit from economies of scale. Massachusetts has eliminated most of its historically ineffective county governments. Even though Massachusetts county governments functioned as administrative arms of the state, and not as mechanisms to deliver local services, county government’s abolition may have produced some misguided skepticism on the effectiveness of regional service delivery.

Peter Harkness wrote recently, “Fragmentation, balkanization, turf protection, silo management—whatever you want to call it—is the toughest dilemma facing public administration today. It is pervasive—within governments, across governments and up and down levels of government. It is the chief contributor to waste, inefficiency and ineffectiveness in our public sector.”2 Massachusetts is a “poster child” for this dilemma. The Commonwealth of Massachusetts has never proposed mandates that force local service delivery coordination or offered incentives to entice collaborative efforts as can be seen in many other states. Although some examples of interlocal collaboration are present in Massachusetts, they are often fragmented and ineffective in assessing and communicating their beneficial impacts. Massachusetts state government has been at best ambivalent toward interlocal collaboration and maintains some laws that hinder such activity. A major disincentive for collaborative activities exists because state law requires that one “lead municipality” dedicate significant resources to organize, process, and coordinate activities on behalf of its partners.3

The two programs described herein make use of collective action to help solve a number of complex issues and problems:

  • Controlling Group Health Insurance Cost

Municipalities, like all public and private organizations today, are challenged by the skyrocketing costs of providing group health insurance coverage for employees. Municipal governments, contrary to private and not-for-profit sector organizations, must deal with cumbersome and outdated statutory requirements that present enormous obstacles to controlling costs. This has resulted in unduly costly health insurance benefits being granted to municipal employees. Some cities are locked into agreements forged more than 20 years ago, and many of them are paying more than 90 percent of group health insurance premium costs.

  • Reducing the Cost of Procurement

Pressure on municipal staff to increase productivity while cutting costs leads to another, less visible, yet significant, advantage of collective action. The National Association of Purchasing Management estimates that for a single purchase transaction of $500, the processing cost is an astonishing $120 to $150.4 It has been observed that the cumbersome and time-consuming public bidding process forces some municipal managers to cut corners and use outdated or poorly written bid specifications. This leaves the municipality exposed to costly legal challenges and delayed service delivery. Poor procurement procedures often result in higher prices.

  • Providing for Code Inspection Services

A lack of staff and financial resources is making it increasingly difficult to perform routine inspections of restaurants and other establishments requiring local permits. Another deficiency exists in measuring the accuracy of retail store scanners and gas pumps. This presents serious public health risks and consumer protection issues.

  • Ensuring Emergency Preparedness

It has been widely reported that incompatible communication systems, a lack of mutual aid agreements, and no single source of public information caused confusion in organizational and public responses during the terrorist events of September 11, 2001. Similar conditions exist in Greater Boston.

The Solution

One of the most promising ways to provide efficient and cost-effective municipal services is through interlocal collaboration. In today’s fiscal climate in Massachusetts, despite formidable political and legal barriers, local officials and voters understand that the choice they will inevitably face to maintain an acceptable level of services is to raise property taxes, pass Proposition 21?2 overrides, or find other ways to control and reduce operating costs. Local government practices traditionally considered inviolable will have to change because local officials will be forced to respond to taxpayers who are more concerned for their bank accounts than protecting antiquated and inefficient governance structures. The solution to these inefficiencies does not require the consolidation of governments, but finding ways to provide services and share overhead costs at an efficient scale. Resourceful local government officials are examining what size “service shed” is appropriate for delivering basic municipal services and bearing their corresponding overhead costs.

The Metropolitan Area Planning Council: Model and Initiatives

The Metropolitan Area Planning Council (MAPC) was established as a state agency in 1963. In 1971, the council’s legislation was amended to make it an independent public body politic and corporate of the Commonwealth. The MAPC is one of 13 regional planning agencies in Massachusetts and is the federally designated economic development district pursuant to the Public Works and Economic Development Act of 1965. In addition, MAPC shares oversight responsibility for the region’s federally funded transportation program as one of 14 members of the Boston Metropolitan Planning Organization.

MAPC’s legislative mandate is to provide technical and professional resources to improve the physical, social, and economic condition of its district, which includes 101 cities and towns in the metropolitan Boston area. MAPC enhances the quality of life and competitive advantage of the Boston metropolitan region in the global economy by providing a focus for action and developing sound responses to issues of regional significance. MAPC’s deliberative process includes broad-based participation from government and the private, nonprofit, academic, and faith-based sectors. MAPC offers research, studies, publications, facilitation, and technical and professional assistance to these constituencies in the areas of land use and the environment, housing, transportation, water resources management, economic development, demographic and socio-economic data, geographic information services, legislative advocacy, and fostering interlocal partnerships that strengthen the efficient and effective operation of local governments.

MAPC is governed by 101 municipal government representatives, 21 gubernatorial appointees, and 10 state and 3 City of Boston officials. An executive committee composed of 25 members oversees agency operations and appoints an executive director. MAPC employs approximately 30 professional and administrative staff. Funding is derived from municipal, state, federal and private grants and contracts, and a per-capita assessment charged to municipalities within the district.

In all its work, MAPC provides an effective nexus for addressing issues of regional significance and interlocal problem-solving. Capitalizing on its role as the sole public body in metropolitan Boston with regional planning as its core mission, MAPC launched ambitious initiatives to facilitate dialogue among its member municipalities to develop a politically viable and sustainable, locally directed mechanism to promote and implement regional approaches to local government service delivery and problem-solving. In so doing, MAPC diversified its planning services portfolio beyond traditional physical, economic, and environmental regional planning. In 1998, the Regional Services Consortiums Project was established. In 2001, the Metropolitan Mayors Coalition was founded.

Regional Services Consortiums Project

Recognizing that if local government initiatives targeted at the politically sensitive subject of cutting costs through regional action are to be successful, they must emerge from municipal officials themselves, MAPC, along with several municipal chief administrative officers, designed and established an organizational model dedicated to identifying and acting on interlocal service opportunities. By mid-2000, three Regional Services Consortiums were operating in the South Shore, Northern, and MetroWest sectors of the MAPC region. Each Consortium is composed of clusters of 11 to 14 geographically proximal municipalities.

The Consortiums are membership organizations. Their primary focus is on collaborative thought and action. They identify and pursue opportunities for cost-effective service delivery through joint effort. Consortium members’ chief administrative officers meet regularly to discuss mutual needs, to identify service gaps and overlaps, and to advise MAPC on their priorities. The concept is unlike conventional approaches to regional efforts that tend to impose a top-down, one-size-fits-all perspective. Instead, the Consortiums are a bottom-up approach to collaboration. They are cost-efficient, lean, results-oriented, and tailored to meet contemporary needs. Membership is voluntary and annually renewable. Performance and value are judged locally. Although their existence is not dependent on state legislative authorization, their capacity to perform is materially restrained by barriers within existing state statutes.

For a nominal annual fee that covers MAPC costs, member municipalities enjoy access to a flexible array of collaborative services that are provided by a MAPC staff member dedicated to the project. Consortium members and MAPC collaborate on the focus and composition of the services. Currently, the membership is focusing on collective procurement. Collective procurement is defined as more than one municipality combining their goods and services needs into one bid specification to strengthen their purchasing power and lower their costs. The MAPC staff member, skilled in public procurement law and process, does the work of the lead municipality. Regionalizing the administration of the public bidding process saves all participants many hours of staff and management time, freeing them up to address more urgent priorities.

Another area being addressed by the Consortiums is municipal employee training. This initiative is designed to provide municipalities with a means to outsource the workload associated with coordinating training events and to produce enrollments collectively that reduce training costs. Last year, over 60 South Shore municipal employees, ranging from police chiefs to public works foremen enrolled in the International City Management Association’s Effective Supervisory Training Program organized by Consortium staff. This internationally recognized program would have been cost prohibitive for municipalities to offer individually.

Having established success with concentrating its collective bidding on road maintenance services and materials and office supplies, the Consortiums are currently filtering an extended menu of opportunities suggested by members and MAPC staff. They range from collective procurement of vehicles, safety equipment, and medical supplies to maintenance services for equipment like emergency generators, elevators, computer networks, and security alarms.

Strategies for meeting a growing need for part-time and on-call code inspection services are also being explored. An approach under consideration would provide these essential services more cost effectively by creating a region-wide bank of inspectors of various disciplines that could be drawn from by member municipalities. The inspectors would work as independent contractors on an as-needed basis.

Metropolitan Mayors Coalition

With strong support from the mayors of Boston and Somerville, the MAPC introduced another collaboration initiative in August 2001. The Metropolitan Mayors Coalition consists of the municipal chief executive officers of the cities of Boston, Cambridge, Chelsea, Everett, Malden, Melrose, Medford, Quincy, Revere, and Somerville. The eight mayors and two city managers work together to foster an environment of cooperation among elected leaders and governments within metropolitan Boston’s urban core. The Coalition serves as a collaborative and consensus-based forum where members discuss and address a variety of critical municipal and intergovernmental issues in a mutually supportive arena. Coalition cities make up only 1 percent of the Commonwealth’s land area, yet they serve 16 percent of its population, and together they comprise a $3 billion municipal market. The Coalition is staffed and facilitated by MAPC and is funded by its members. Recently, the Coalition was awarded significant assistance, both financial and symbolic, from The Boston Foundation.

Members meet periodically to confer and reach consensus on major policy initiatives and direction; they refer their decisions to senior city staff members who form work groups focused on each issue. They further retain experts to provide more sophisticated analysis of more complicated issues.

The Metropolitan Mayors Coalition is the first of its kind in Massachusetts and serves as an effective vehicle for the cooperative development of a coordinated response to complex challenges. Currently, there are three issues on the Coalition’s agenda:

  • Controlling the Cost of Group Health Insurance

The City of Boston is the largest municipal consumer of group health insurance in New England. In FY 2002, Boston experienced a whopping $18 million increase in its total group health insurance budget. Combined increases for the nine cities during the same period amounted to $31 million. Percentage increases averaged 13 percent, ranging from a low of 11 percent in Boston and Cambridge to a high of 26 percent in Revere and Somerville. Collective appropriations amounted to a staggering $271 million or an average of 8.29 percent of total operating budgets. With no end in sight for these huge increases, the Coalition cities are engaged in an analysis of group health insurance programs and costs to see if collective action could help control the crippling increases being levied upon them. The goal is to provide the same or similar benefits to municipal employees at the least possible cost.

One strategy currently being pursued is to consolidate all of the cities’ health care programs into the City of Boston’s programs, initially focusing on three of the most popular HMOs (HMO Blue, Tufts, and Harvard Pilgrim). Boston and Chelsea have been in this type of arrangement since 1996. In FY 2002, Boston’s budget for these three HMOs amounted to approximately $96 million. The combined cost of the same programs for all other Coalition cities was approximately $32 million. Historically, Boston, due to its size, has been able to achieve more favorable results than other Coalition cities when negotiating rates with carriers, generally around 3.4 percent. Adding $32 million to Boston’s purchasing power will significantly strengthen its negotiating position with insurers and provide substantially more clout than a city the size of Revere or Melrose could wield on its own. Recently, Boston received notice of its FY 2004 premium rates from Blue Cross/Blue Shield, Tufts, and Harvard Pilgrim. Boston officials have indicated that increases are significantly higher than expected, and they are negotiating with these carriers to lower the premium rates that were presented. At the same time, Boston is proposing ambitious benefit modifications to its employee groups. Boston’s negotiations with both its insurers and employees will probably be settled by late spring of 2003. At that time, negotiations with employees can commence in the Coalition cities aiming toward a July 1, 2004 consolidation.

Although much of the technical analysis has been completed and preliminary results are encouraging, there is still much work to be done. The work must now focus on financial and administrative arrangements, legal considerations, and collective bargaining implications with the 130 municipal unions established within the nine cities. Perhaps most challenging will be the stance that the group health insurance carriers will take.

  • Reducing the Cost of Procurement

Similar to the Regional Services Consortium’s collective procurement program, the Coalition has finalized a protocol that allows its members to take advantage of economies of scale in the procurement of goods and services. This model relies on Boston’s procurement department, with assistance from Coalition staff, for implementation. Simply arranging for member cities to buy through Boston’s contracts, a process slightly different from the approach at work in the Regional Services Consortiums, will result in significant savings to Boston and its neighbors. The Coalition launched its first collective bid in April 2003. The cities of Cambridge and Somerville joined Boston in a $2.8 million solicitation for office supplies, copy paper, and light bulbs. Other consumable products are under active consideration. Once processes are established and tested, more complex initiatives such as the joint purchase of cellular services, energy, and energy efficient products will be pursued.

  • Ensuring Emergency Preparedness

The Coalition is implementing a plan that would set aside a portion of each city’s first allotment of federal homeland security planning funds to conduct a study to identify emergency preparedness deficiencies and explore ways in which its cities can more effectively coordinate emergency management planning. Based on a briefing from the Massachusetts Emergency Management Agency, Coalition cities will be granted a total of $280,000. In addition, a resource matrix is being produced that will provide the Coalition emergency management directors with an inventory of assets that they could share in the event of an emergency. The Coalition is represented and is actively participating on the United States Coast Guard’s Model Port Program Steering Committee, which is focusing on the security and commercial vitality of Boston Harbor.

The Coalition sponsored six bills that were filed by various member cities for consideration during the 2003-04 legislative session. The bills address issues such as affordable housing, creating a trust fund for energy conservation programs, revenue enhancements, and after school programs. More recently, the Coalition has produced a comprehensive “core elements of municipal relief” for presentation to the legislature as it debates the 2004 state budget.

Costs and Benefits

Table 1 illustrates the annual cost of operating a regional services consortium. The costs are similar for the Metropolitan Mayors Coalition. Of course, costs can differ depending on the level of service demand. This project budget covers a single project director operating three consortiums totaling 36 municipalities. The costs are divided among the participating municipalities; hence the more participants the lower the cost for all—up to the point where another staff person is needed. The Regional Services Consortium Project is approaching the point where additional membership will require increased staffing.

Currently, the fee for service is $4,000 per municipality per year for the Regional Services Consortium. In three years of operation, the Regional Services Consortiums Project has processed collective procurements on behalf of its 36 member municipalities totaling nearly $41 million in goods and services. Savings realized have exceeded $2.3 million, representing an 840 percent return on investment across the region.5 A water system leak detection program was procured on behalf of the Northern Consortium that resulted in the detection of 275 million gallons of potable water leaking per year from pipes in the water distribution systems surveyed.

Since local officials are always concerned about performance and tangible evidence that savings are being realized, MAPC has built price-monitoring analyses into its reporting routine. The longer range goal is to achieve real-time price comparison that accompanies each procurement.

While actual dollar savings are important, there are less tangible, yet significant benefits derived from these collaborations. The Regional Services Consortium Project has estimated that administering one public works bid centrally saves over $2,600 in staff time and advertising costs per participant, not to mention a better quality specification. It makes inherent sense that it is far more efficient and certainly less costly to hold a procurement event once rather than 36 times for the same item. This is true for both the supplier and the consumer.

While seeking to gain a better understanding of why street paving prices were approximately 10 percent higher in the Northern and MetroWest Consortiums as compared to the South Shore Consortium, it was discovered that the road paving industry had created a near monopoly inside Interstate 495 and a virtual monopoly inside MA-128. Although an unintended result of collective procurement, it is an important example of how the procurement of goods and services regionally permits a macro analysis of the multi-billion dollar municipal marketplace that would not otherwise be conducted locally.

Obviously, it is nearly impossible to document the return on investment for employee training, improved emergency preparedness, and legislative advocacy. The value of forums that provide for collegial and professional exchange among mayors and city/town managers that are geared toward collaborative problem-solving and policy and program brainstorming cannot be underestimated.

Membership in these initiatives has been strongly supported by local chief administrative officers, elected officials, and town meetings. That support endorses the belief that collaborative action results in mutual benefits.


The following discussion highlights some of the obstacles that threaten to impede the progress that could be achieved by the Regional Services Consortiums Project, the Metropolitan Mayors Coalition, and other collaborative efforts being pursued or contemplated throughout Massachusetts. Four of the most critical impediments are discussed below.

  • No State Incentives or Disincentives

Massachusetts does not overtly encourage municipal collaboration, despite regular political rhetoric praising such endeavors. It neither rewards collaborative action nor punishes a lack of it.

  • Overly Restrictive Controls on Municipal Procurement

The law authorizing municipalities to engage in collective purchasing lays out a cumbersome mechanism that places the administrative burden for the procurement process on a “lead municipality.”6 In addition, it steers the collaborating group back to statutes controlling municipal procurement that place serious encumbrances on collective ventures.7 The statute that authorizes collective procurement by the Commonwealth is, by contrast, far more flexible.8 It allows public entities to “piggyback” on state bids without having to be involved in the procurement event before it is advertised. The authority to follow the process applicable to the Commonwealth should be granted to non-state entities engaged in collective procurement.

Other states, Texas for one, permit access to the most liberal procurement methods available to governments acting collaboratively.9 It saves immeasurable amounts of time and provides all who choose to partake with the best price available. Massachusetts needs to give more flexibility to municipalities to procure goods and services collectively. The state should invest in a municipal e-procurement system to be operated by regional entities like MAPC. Although the Commonwealth has developed a fairly sophisticated statewide procurement system, it is, and always will be, responsive to state agencies, its major customers. State agencies and municipalities have very different needs.

  • Municipal Group Health Insurance Statute

The Massachusetts Group Health Insurance law is antiquated and cumbersome.10 The law makes it almost impossible to bargain with unions for increased contributions or co-payments. Under the law, cities and towns cannot alter the health plan of a single employee union. Instead, they must bargain with all unions simultaneously. This is a monumental task for larger cities that have between 10 and 100 different collective bargaining units. This provision rules out any strategy by which cities and towns could negotiate with unions one by one. Still worse, the law demands that all public employees in a given municipality receive the same benefits. The situation has been characterized as a knot defying anyone to untie it.

Recently, the Metropolitan Mayors Coalition asked Governor Romney to consider capping municipal contributions to group health insurance premiums at 80 percent. He responded by proposing a 75 percent cap. Although Romney’s proposal is encouraging, the whole statute needs to be overhauled. Again, by contrast, the law governing state employee group health insurance is far less restrictive. Massachusetts has relieved itself of collective bargaining obligations and has given the legislature the authority to set employee contribution levels.

  • Intermunicipal Services Agreement Statute

The statute authorizing intermunicipal service agreements actually serves as a deterrent.11 The statute requires local legislative approval for all such agreements. This makes it difficult to take swift advantage of opportunities since most towns’ legislative bodies meet once or twice a year. Getting town meetings and city councils involved in authorizing intermunicipal agreements is an infringement on executive authority and is unnecessary and cumbersome. Local legislative approval for contracts lies in the appropriation process. Statutorily, municipalities are authorized to enter into contracts for the exercise of any of their corporate powers for any period of time deemed to serve their best interest. That statute should suffice for contracts between and among local governments.

Replication: Models from other States

The State of Georgia links collaborative service delivery to state financial assistance. Localities that demonstrably participate in collaborative practices see their state financial assistance increase. Those that do not see their state financial assistance decline. Georgia rewards municipalities that act responsibly with the taxpayers’ money and holds them accountable for cost-effective performance.12

Minnesota, New York, and Virginia offer competitive grants that fund innovative interlocal projects. In 2000, the State of New Jersey awarded $16.2 million to 130 towns under that state’s Regional Efficiency Aid Program.13 There are other good examples of state-local partnerships to improve public services throughout the nation. Massachusetts needs to examine the successful efforts of its counterparts to encourage local government efficiency through interlocal action. Massachusetts should create through state law and regulations an atmosphere that encourages and even provides direct incentives for locally driven collaboration.


Overcoming the barriers to interlocal collaboration can only be achieved through the Massachusetts General Court, spurred on by strong executive leadership from the Governor. The current fiscal and political climate makes these reforms seem plausible.

The support of local elected and appointed officials for the Regional Services Consortiums Project and the Metropolitan Mayors Coalition reflects a grassroots political shift away from steadfast parochialism toward prudent collaboration. The Consortiums’ quantifiable taxpayer benefit was recognized by former Massachusetts House Minority Leader Francis Marini, former Representative John Stefanini, and Senator David Magnani. They were successful in earmarking $110,000 in the Commonwealth’s FY 2001 budget as seed money for the Consortiums Project. The potential of the Metropolitan Mayors Coalition was acknowledged by The Boston Foundation, the largest philanthropic organization in New England. Boston Mayor Thomas M. Menino’s support and personal involvement in the Coalition have been crucial, as has been Somerville Mayor Dorothy Kelly Gay’s leadership.

These initiatives are being embraced because local officials recognize the benefits of seeking economies of scale and that the complex problems facing local government cannot be solved in a vacuum. Reducing and controlling operating expenses are a performance measurement for appointed officials and are politically popular for elected officials. Despite the Massachusetts municipal home rule psyche, it is becoming widely accepted that interlocal cooperation is in everyone’s self-interest. Participation in interlocal enterprises builds the trust that is essential to pursue complex and challenging propositions like the group health insurance consolidation plan under consideration by the Metropolitan Mayors Coalition.

Opportunities for interlocal cooperation, such as collective procurement and shared service delivery, are abundant. Town managers and mayors have floated ideas that include an interjurisdictional approach to youth violence, regional alternative schools for expelled students, shared police training facilities, and shared crime laboratories. The level of interest and enthusiasm is encouraging, yet the Consortium Project and the Metropolitan Mayors Coalition must expand to keep up with demand.

Local governments are on the front lines of the nation’s public service delivery system. Metropolitan Boston’s cities and towns can serve as an example of how to deliver services creatively and cost effectively. To realize this potential, a meaningful, productive, mutually supportive and healthy partnership, like the one that has been cultivated between MAPC and local governments, will need to be forged with our Commonwealth.

While the new Governor searches for ways to streamline state government, he should study what is being accomplished by the collaborative projects sponsored by MAPC. After all, local government is one of the state’s major and most important investments. The Commonwealth needs to support collaborative initiatives, both financially and through statutory and regulatory relief.

About the Author

Stephen McGoldrick has been the deputy director of the Metropolitan Area Planning Council since November 1997. Before joining the council, he provided management consulting services to local governments, public school systems, and housing authorities. From 1991 to 1996, he served as chief of staff to the Chelsea receiver and subsequently facilitated the establishment of Chelsea’s post-receivership government as the Commonwealth’s transition officer. He has held leadership positions in three mayoral administrations in Everett and Somerville. In 1996, Mr. McGoldrick co-authored the Final Report of the Regionalization Commission, a study group established and chaired by Boston Mayor Thomas M. Menino.

  1. Massachusetts Department of Revenue, Division of Local Services, City of Springfield Financial Review, April 2003.
  2. Peter A. Harkness, Publisher’s Desk, “The U.S. Balkans,” Governing Magazine, April 2003.
  3. Massachusetts General Laws, Chapter 7, Section 22B.
  4. Kenneth Mitchell, “Instituting E-Procurement in the Public Sector,” Public Management, November 2000.
  5. Annual Reports to members.
  6. Massachusetts General Laws, Chapter 7, Section 22B.
  7. Massachusetts General Laws, Chapter 30B.
  8. Massachusetts General Laws, Chapter 7, Section 22A.
  9. Houston-Galveston Area Council (http://www.h-gac. com).
  10. Massachusetts General Laws, Chapter 32B.
  11. Massachusetts General Laws, Chapter 40, Section 4A.
  12. Georgia Department of Community Affairs (http://
  13. New Jersey Department of Community Affairs ( dca).
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